Privacy Policy

Mod.: IS – Updated 10/2024

Information on the processing of personal data.

Articles 13 and 14 of EUROPEAN REGULATION No. 679/2016

Legislative Decree 196/2003 amended by Legislative Decree 101/2018

Dear Data Subject,

This notice describes the management methods of the website concerning the processing of personal data of users who consult it, as well as the data processing practices through this site. In compliance with Articles 13 (for data collected from the data subject) and 14 (for data not collected from the data subject) of Regulation (EU) 2016/679 (hereinafter referred to as GDPR), the following information is provided to users of this website. This information applies exclusively to the processing carried out through this website and not through other websites that may be visited via links from this one, for which it is recommended to refer to the respective privacy policies provided by the respective controllers.

This website and any services that may be offered through it are reserved for individuals who are at least eighteen years of age. The data controller, therefore, does not process personal data related to individuals under 18 years old. Upon request from such users, the controller will promptly delete all personal data inadvertently collected.

1.Data Controller

The Data Controller is Genesi S.R.L., with registered office at Via W. Tobagi 37, 46040 Casaloldo (MN), Italy, Tax Code and VAT No. 01912270202 (hereinafter "Controller"). The Controller reserves the right to appoint a web agency or consultant as the Data Processor for the purposes of technical support, maintenance, technical management, and similar activities related to this Website. The details of such Processor can be provided upon request to the addresses mentioned above. Both the Controller and the Processor handle the Users' data through their own internal staff, who are specifically designated and authorized to process the data according to given instructions.

2.Categories of Data Processed and Sources

Browsing data: The IT systems and software procedures used to operate this website acquire, during their normal operation, certain personal data, the transmission of which is implicit in the use of Internet communication protocols. This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and addresses of websites from which access or exit was made, information on the pages visited by users within the site, the access time, time spent on individual pages, internal path analysis, and other parameters related to the user’s operating system and IT environment. These technical/IT data are collected and used exclusively in an aggregated and anonymous manner. They are processed with the aim of ensuring and controlling the correct use of this website, as well as to obtain anonymous statistical information about its use. The data are immediately deleted after processing.

Cookies: Please refer to our Cookie Policy.

Data voluntarily provided by the user, including:

Common data (e.g., identification, personal details, billing information, etc.)
Exceptionally, special data (Art. 9 GDPR)
Exceptionally, criminal data (Art. 10 GDPR)

Sources: Browsing, other websites, cookies, and similar technologies; the user; public sources.

We may primarily process browsing data, as well as cookies.
We may also process data voluntarily provided by the user, for example, through a contact form or an email communication. These may include common personal data (e.g., identification, personal details, billing information) and, exceptionally, special data under Art. 9 GDPR or criminal data under Art. 10 GDPR, but only within the strict limits required by the user’s request and with the user’s consent.
Data may originate from automatic or voluntary sources, as well as public sources. For instance, they may come from the user’s browsing activity, which may carry information related to previous visits to other websites, including, in particular, cookies and other similar technologies. Data may also be voluntarily provided by the user or by parties related to the user. Other data may come from public sources, such as those processed in research, public records, databases, and similar resources.

3. Purpose of Data Processing

The personal data of the Website Users, as described above, will be processed in accordance with the methods and forms prescribed by the GDPR, for the purpose of fulfilling the functionalities of the Website, particularly (but not exclusively) concerning navigation of its pages, the data collection procedures described therein, contact forms, potential registration/access to the reserved area, newsletter subscription, and similar activities. Specifically, the personal data provided to the Controller will be processed for the following purposes:

To respond to specific requests made by the User to the Controller through the Website and its communication tools (contact forms, information request forms, and similar);
For informational communications related to the Controller’s services, following requests for information via email or completion of contact forms and other communication tools;
For potential registration for events organized by the Controller and related activities (e.g., verification of participation, notifications regarding updates or changes to the event, etc.);
For other purposes accessory to or connected with those listed above and falling within the scope of the Website’s activities.

The processing of data provided in a general manner will also be carried out, including data automatically collected during browsing, solely for the purposes of verification and control of access to the Website. This also applies to technical cookies, understood as session, functionality, or analytics cookies that meet the criteria specified by the Data Protection Authority. In particular, with regard to the latter, it is clarified that they may be considered technical cookies when they are created and used directly by the Website. In any case, for these analytics cookies, the Website, in compliance with the clarifications provided by the Data Protection Authority, has implemented anonymization of IP addresses and amended data processing. The collection and use of the aforementioned browsing data (while ensuring the anonymization of IP addresses) allow for monitoring the performance of the Website and improving the service offered, providing the User with a better browsing experience. For further information, please refer to the specific Cookie Policy.

4. Legal Basis for Processing

The processing of personal data is based on the fulfillment of contractual or pre-contractual obligations related to the User's request (e.g., requests for information about the Controller’s services, quote requests, etc.), and, where necessary, on the User’s consent, provided by the voluntary and informed completion of the appropriate fields in the data collection form and the ticking of the relevant checkbox where applicable.
It is noted that filling out the specific fields in the information request forms is inherent to the request itself and, therefore, constitutes fulfillment of a pre-contractual or contractual obligation, depending on the context. Consent may be requested subsequently for the processing of additional data.
A specific privacy notice will be provided wherever necessary (different from this one).
In any case, the processing is also based on the Controller’s legitimate interest, including the right to provide information, as described in the next paragraph.

5.Legitimate Interest of the Controller

The processing of personal data is also based on the Controller’s legitimate interest, such as exercising its rights in the context of the information society, performing the contractual obligation, and conducting direct marketing operations (in the ways, means, and times provided by law).

6.Mandatory Nature of Data Provision

The provision of navigation data by Users, for the purposes mentioned above, depends on the level of privacy the User has enabled or disabled through their browser. In some cases, disabling may affect the ability to browse this Website. For certain sections of this Website, the provision of navigation data and/or the use of technical cookies is mandatory for the correct functioning of the Website.
The provision of certain personal data is, in any case, necessary for the structure of the Website and its procedures. Any request for additional optional data will be preceded by the appropriate approval checkbox. Providing all other data is optional, depending on the type of information the User wishes to provide to the Website.

For example, providing an email address is necessary to respond to requests made via the contact form, as well as other required data indicated with an asterisk. Other data are optional.
Failure to provide the data necessary for the requested action (e.g., the email address via the information request form) makes it impossible for the Controller to fulfill the request.

APPLICABLE PROVISIONS FOR ALL DATA PROCESSING
In any case, even if the data subject has consented to the Controller processing all the purposes mentioned above, they remain free to revoke it at any time.
It is specifically and separately noted, as required by Article 21 of the Regulation, that the data subject has the right to object at any time to the processing of their personal data carried out for the above purposes. If the data subject objects to the processing, the personal data can no longer be processed for those purposes.

7. Potential Recipients of Personal Data

The data may be communicated to companies affiliated, associated, or controlled by the Data Controller, as well as to consultants or third parties acting on behalf of the Controller for the fulfillment of services related to the purposes specified in this notice, both within and outside the EU (in the latter case, only to entities adhering to current regulations).
Browsing data and similar (as mentioned above), as well as third-party profiling cookies (for which reference is made to the Cookie Policy of this Website), will be communicated to the respective third parties where they do not manage them directly as Data Controllers.
In any case, data may be communicated to Data Processors and authorized individuals, duly trained, and always within the scope of the purposes of processing.
For brevity, the detailed list of such figures is available at our headquarters.

8.Data Retention Period

The data voluntarily provided by the Data Subject will be retained until the Data Subject explicitly withdraws consent, either by taking action through their browser (clearing cookies), submitting a specific request, or by other means. Browsing data will be retained, respecting the principle of proportionality, in a form that allows the identification of the Data Subject for no longer than is necessary for the purposes for which they were collected or subsequently processed.
Excluded from the aforementioned terms are cases where it is necessary to retain the data for an additional period to defend or assert a right or to comply with legal obligations or orders from Authorities.

9. Data Subject's Rights

Each Data Subject has the right to access, rectify, erase (right to be forgotten), restrict, receive notification in case of rectification, erasure, or restriction, data portability, object, and not to be subject to automated individual decision-making, including profiling, under Articles 15 to 22 of the GDPR. These rights can be exercised in the forms and terms specified in Article 12 of the GDPR by sending a written communication to the Controller (see section 10).
The Controller will respond appropriately as soon as possible and, in any case, within 1 month of receiving the request.

10.Right to Withdraw Consent (How to Exercise Rights)

It is possible to withdraw consent, where provided, at any time and/or exercise your rights by sending:
– A registered letter with return receipt to the address of the Controller (see the address on the letterhead);
– An email to the address: genesi@genesi-seamless.it

11.Complaints

Each Data Subject has the right to lodge a complaint under Articles 77 and following of the GDPR with a supervisory authority, which for Italy is identified as the Data Protection Authority. The forms, methods, and terms for filing complaints are provided and regulated by current national legislation. The complaint does not affect the possibility of administrative and judicial actions, which in Italy may be filed alternatively with the same Data Protection Authority or the competent Court.

12.Profiling

The personal data provided through browsing this website and the possible completion of forms published herein may be subject to profiling by third-party providers via third-party cookies.
Profiling allows these third-party providers, who are independent data controllers for profiling purposes and different from the Controller of this website, to evaluate certain personal aspects of the Data Subject, particularly their preferences, interests, and tastes regarding the pages viewed and activities performed, in order to offer a more specific and tailored service to the Data Subject.
For more information, the User is invited to read the Cookie Policy.

13. Controller, Authorized Personnel, Data Processors

Below, we provide some information that you need to know, not only to comply with legal obligations but also because transparency and fairness toward the data subjects are a fundamental part of our activities.
Data Controller : The Data Controller of your personal data is Genesi S.R.L., responsible for the legitimate and correct use of your personal data, and can be contacted for any information or requests at the following contact details: phone +39 0376 781118, email: genesi@genesi-seamless.it.
Authorized Personnel : The updated list of individuals authorized to process data is kept at the headquarters of the Data Controller.
Data Processors : For brevity, the detailed list of such figures is available at our headquarters.

14.Social Media Plug-ins

This site may contain plug-ins for certain social media (e.g., Facebook). Social plug-ins are special tools that allow the integration of social network functionalities directly within the website (e.g., the Facebook "like" button) and are identified by the logo of the respective social platform. When visiting a page on this site and interacting with the plug-in (e.g., by clicking the "like" button) or choosing to leave a comment, the corresponding information is transmitted from your browser directly to the social network platform (in this case, Facebook) and stored there. For information on the purposes, types, and methods of collection, processing, use, and retention of personal data by the social network platform, as well as how to exercise your rights, please refer to the privacy policy of the social network.

15.Links to Third-Party Sites

From this site, it is possible to connect via dedicated links to other third-party websites. The Controller disclaims any responsibility for the possible management of personal data by third-party sites and for the management of authentication credentials provided by third parties.

16.Cookies

Cookies are packets of information sent by a web server (e.g., the website) to the user’s Internet browser, automatically stored by the browser on the computer, and automatically sent back to the server each time the site is accessed. For information on the characteristics, types, usage methods, and ways to remove, delete, or disable cookies present on the website, please refer to the specific Cookie Policy.
Data Controller : Genesi S.R.L.

Contact Us
Genesi S.R.L. welcomes comments regarding this privacy policy.
Please contact us at the following address: genesi@genesi-seamless.it

Mod. ICONT – Data Agg. 05/2024

Privacy Policy for Personal Data Processing
Pursuant to Article 13 of the European Regulation No. 679/2016

Dear Data Subject,
Genesi S.R.L., as the Data Controller pursuant to Article 13 of European Regulation No. 679/2016 "General Data Protection Regulation (GDPR)" (hereinafter referred to as "EU Regulation"), concerning the processing of personal data, wishes to inform you regarding the processing of your personal data.
The regulation stipulates that anyone processing personal data is required to inform the data subject about the data being processed and the relevant details of the processing, which must always be carried out lawfully, fairly, and transparently, while protecting confidentiality and ensuring the rights of the data subject.
It is noted that "data processing" refers to any operation or set of operations concerning the collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, or destruction of data.

1. Data Controller

The Data Controller is Genesi S.R.L., with its registered office at Via W. Tobagi 37, 46040 Casaloldo (MN) Italy, VAT number and tax code 01912270202, and can be contacted at the following contact points: phone +39 0376 781118, email: genesi@genesi-seamless.it.

2. Nature of the Data Processed, Purposes, and Legal Basis of the Processing

Nature of the Data Processed. In relation to the purposes of the processing listed below, please note that only "common personal data" will be processed, such as:

Company identification data (name, surname, email, etc.);

Purposes of the Processing. Your personal data will be processed for the following purposes:

Responding to your requests: by voluntarily filling out the appropriate form in this contact area;
Complying with legal obligations;

Legal Basis of the Processing. The personal data, for the purposes listed in points 2A and 2B, will be processed lawfully to fulfill pre-contractual and contractual obligations between us and the user (Art. 6, Para. 1, Letter b) and to comply with our legal obligations (Art. 6, Para. 1, Letter c).

3. Data Recipients and Processing Methods – Automated Decision-Making, Including Profiling

Your personal data will be processed in compliance with the principles of fairness, legality, and transparency, using both paper and electronic tools. It may be processed by authorized employees of the company or external entities performing specific tasks on behalf of the Data Controller, as Data Processors pursuant to Article 28 of the EU Regulation, with prior appointment that imposes confidentiality and security obligations for personal data processing, and the adoption of appropriate security measures to prevent data loss, unlawful and improper use, and unauthorized access, in compliance with current personal data protection laws.
For brevity, a detailed list of these entities is available at the Data Controller’s office and is available upon request.
Your personal data will not be disseminated and will not be transferred to third countries or international organizations, nor will it be communicated to third parties unless required by law or contractual obligations.
In accordance with Article 13, Para. 2, Letter f) of the EU Regulation and Article 14, Para. 2, Letter g) of the EU Regulation, we inform you that, currently, the Data Controller does not use any automated decision-making or profiling systems.

4. Data Retention Period

Your personal data will be retained for a period not exceeding the purposes for which they are processed, in compliance with the principle of storage limitation as outlined in the EU Regulation and/or for the time required to fulfill legal and contractual obligations, or until specific consent is withdrawn by the data subject.
With reference to the purposes listed under points 2A and 2B, the data will be retained for a period not exceeding the achievement of the purposes for which they are processed and/or for the time strictly necessary to fulfill legal and contractual obligations.
To ensure compliance with declared retention periods, an annual review of the data will be conducted to verify whether they can be deleted if they are no longer necessary for the intended purposes.

5. Access to Data (Categories of Recipients to Whom Data May Be Communicated)

Please be informed that the collected data will never be disseminated and will not be communicated without your explicit consent, except for the necessary communications that may involve the transfer of data to public entities, consultants, or other subjects for the fulfillment of tax and legal obligations or the fulfillment of the purposes (where authorized), with prior appointment that imposes confidentiality and security obligations for the personal data processing.
In accordance with Article 13, Para. 1, Letter e) of the EU Regulation, the following is a list of subjects or categories of subjects (duly appointed and instructed) who may become aware of the user's personal data as processors or persons in charge of the processing:

Partners, employees, collaborators, and suppliers of the Data Controller, in Italy and abroad, in their capacity as persons in charge/authorized and/or responsible for processing (e.g., commercial, technical, administrative, legal, and press offices; system administrators, external professionals, service providers, etc.);
Partner companies and/or directly linked to the company, as their activities are essential for completing/executing your request.

Your personal data may also be communicated to external subjects involved in your procedures, in the performance of activities, and to external subjects who interact with the company, always and exclusively for activities related to the above purposes, as external processors, pursuant to Article 28 of the EU Regulation.
For brevity, the detailed list of these entities is available at our headquarters and is available to you upon request.

6 & 7. Data Communication and Transfer

Without the need for explicit consent (Art. 6, Para. 1, Letters b), c), and f) of the EU Regulation), the Data Controller may communicate your data for the purposes listed under points 2A to 2F to supervisory bodies, judicial authorities, and entities to whom the communication is mandatory by law for the accomplishment of the above purposes.
These subjects will process the data in their capacity as autonomous data controllers.
Personal data are stored on devices located at the Data Controller's headquarters or with providers within the European Union.
Your data will not be disseminated.
To ensure the security of such transfers, we use only entities that provide adequate safeguards to implement appropriate technical and organizational measures so that the processing complies with the requirements of Regulation EU 679/2016.

Both for the data stored on our own devices and for any data stored with providers, the Data Controller has implemented adequate technical and organizational measures to ensure an appropriate level of security, in full compliance with the provisions of the EU Regulation.

8. Consequences of Failure to Provide Data

The personal data referred to in points 2A-2B of this information notice are necessary; without such data, it would be impossible for us to proceed and fulfill our contractual and legal obligations.

9. Rights of the Data Subject

As a data subject, you have the rights outlined in Articles 15 to 22 of the EU Regulation, including but not limited to the right to:

Obtain confirmation of the existence and processing of personal data concerning you, and if so, access your data (right of access);
Obtain details about the purposes of the processing, the categories of data, the recipients or categories of recipients to whom the data have been or will be disclosed, particularly if recipients from third countries or international organizations, the expected retention period, or the criteria used to determine that period; and, if the data are not collected from the data subject, all available information regarding their origin;
Obtain rectification of inaccurate data concerning you (right to rectification);
Request the deletion of your data (right to erasure);
Obtain restriction of processing (right to restriction of processing);
Receive the data in a structured, commonly used, and machine-readable format, and transmit it to another data controller without hindrance (right to data portability);
Object to the processing at any time (right to object). Specifically, as required by Article 21 of the EU Regulation, if personal data are processed for direct marketing purposes (including profiling), you have the right to object at any time to the processing of personal data concerning you for these purposes. If you object to processing for direct marketing purposes, the personal data will no longer be processed for these purposes;
Be informed of the existence of automated decision-making, including profiling, and have the right to object;
Revoke consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal;
Lodge a complaint with a supervisory authority (Data Protection Authority).

Please note that certain conditions or limitations may apply to the rights of the data subject. For example, it is not certain that the right to data portability will apply in all cases; this depends on the specific circumstances of the processing activity.
Another example: if you decide to object to the processing of data, the Data Controller has the right to evaluate your request, which may not be accepted if there are compelling legitimate grounds for processing that override your interests, rights, and freedoms.

10. Methods of Exercising Your Rights

You may exercise your rights at any time without formalities by sending:

A registered letter to the Data Controller;
An email to genesi@genesi-seamless.it
Alternatively, you may contact the Data Controller directly at +39 0376 781118.

11. Minors

The services offered by the Data Controller and subject to the current relationship do not involve the intentional collection of personal information relating to minors. If information concerning minors is unintentionally recorded, the Data Controller will delete it promptly at the request of the users.

Genesi S.R.L.

Via W. Tobagi, 37
46040 Casaloldo (MN) Italy
VAT Number: 01912270202

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